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Case Digest: Fua Cam Lu vs Yap Fauco and Yap Singco 74 Phil 287, G.R. No. L-48797

Fua Cam Lu vs Yap Fauco and Yap Singco 74 Phil 287, G.R. No. L-48797, July 30, 1943

Subject: Obligations and Contracts

FACTS

By virtue of a judgment for P1,538.04 which Fua obtained against Yap, a writ of execution was issued in pursuance of which a parcel of land belonging to Yap was levied upon and its sale at public auction duly advertised. The sale was, however, suspended as a result of an agreement between the parties, by the terms of which the obligation under the judgment was reduced to P1,200 payable in four installments, and to secure the payment of this amount, the land levied upon with its improvement was mortgaged to appellee with the condition that in the event of appellants' default in the payment of any installment, they would pay 10 percent of any unpaid balance as attorney's fees as well as the difference between the full judgment credit and the reduced amount thus agreed. Appellants failed to comply with the terms of the settlement, whereupon, appellee sought the execution of the judgment, and by virtue of an alias writ of execution, the land was sold at public auction to appellee and a final deed was executed in his favor. Appellants refused, however, to vacate the land and to recognize appellee's title thereto; hence, the latter instituted the present action for recovery.

ISSUE

Whether or not there was extinctive novation.

RULING

Yes, there was extinctive novation, in view of the incompatibility between the judgment and the contract, considering the fact that the judgment was payable at once, was unsecured, and contained a stipulation for attorney’s fees.

In this case, the contract was NOT a mere extension of the period within which to pay the judgment because the contract itself stated that the promise to pay the P1,200 was precisely made as a settlement of said judgment. There would have been no settlement had it not been implicitly agreed that the obligation in the judgment was considered by both parties as already extinguished.

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